The half-yearly hiatus in 'normal' life, which is the FCA's RMAR is upon us again. Every six months, I am amazed afresh at how over-engineered, inefficient, irrelevant and simply flakey the whole process is. And expensive. The FCA's systems ('Gabriel') totter along in a barely functional manner, demanding that the user forever compensates for its own dysfunctionality.
This time around, as in pretty much every other historic iteration of this purgatory, there's another problem on the system. Items of data which we've input successfully many times before are now suddenly unacceptable to Gabriel. Inwardly, we grind our teeth and mutter, "Gabriel ain't no angel" as we have done on numerous occasions. We promise ourselves that, if we manage the thing successfully, we'll close the office and take everyone down the pub: nobody even bothers to get their hopes up, because by now they know the reality of the thing.
So, we put a call through to the FCA Firm Contact Centre, and even before we speak to an operative, we've had to spend some time listening to messages telling us that there are "issues with Gabriel". You betcha. I strive hard to keep the petulance out of my voice as I explain the issue, and it turns out that this is another matter that the support team are unaware of. I spend a long time listening to canned music whilst the operative goes away to ask questions, and the only outcome from this is that I now wake up each morning with the tune playing through my mind. A horrible legacy from the interaction.
The operative runs out of ideas, and promises to 'phone back, but not before she has suggested random alternatives in the data-entry - such as recategorising our firm. This might strike one as a surprising suggestion, but in FCA World, this is par for the course. We have received this kind of advice on a number of occasions previously: if the Gabriel cannot handle accurate data, then the answer is to fudge the answers we give, so that Gabriel will allow us to submit the return. Yep, you couldn't make it up.
To be fair, ValidPath are not a huge firm, and therefore if the reporting is 'tweaked' (at the FCA's suggestion) in some area, it surely cannot have significance on a cosmic scale. But then again, Chaos Theory tells us that the fluttering of a Red Admiral butterfly's wings in the Amazon, could trigger a hurricane in the Pacific. Besides which, the very idea does go against the grain: surely the veracity of data matters? It's not just about ethics and truthfulness, but it's about the value of the data itself: if it is important enough to ask for it, then it is important enough for it to be right.
To date, the FCA operative has not 'phoned back, so ValidPath remain in limbo. In the meantime, I am left reflecting on the broader issue of how we engage with the data that we use, in the course of our work. It seems to me that data matters, not just because it is personal to each client and therefore should accurately reflect their circumstances, objectives, preferences and values, but also because our role is to make use of it, to make sense of apparent chaos, to identify patterns, run meaningful diagnostics and make reliable financial prescriptions which will transform our clients' lives for the better.
A related resource...
ValidPath's practice management system, Clarity, has excellent FactFinding technology, allowing the user to consolidate all of the client's financial data, and then quickly generate an editable client report of both considerable breadth and depth.